Amos v. Comm'r
United States Tax Court
Held, that amounts received by a district director, as agent for respondent, from notices of levy served on a bank and an insurance company to reach property of petitioner-husband constitute involuntary payments which the district director has a right to apply as he chooses to outstanding assessments of tax, penalty, and interest. O'Dell v. United States, 326 F. 2d 451 (C.A. 10, 1964), followed.
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Held, that amounts received by a district director, as agent for respondent, from notices of levy served on a bank and an insurance company to reach property of petitioner-husband constitute involuntary payments which the district director has a right to apply as he chooses to outstanding assessments of tax, penalty, and interest. O'Dell v. United States, 326 F. 2d 451 (C.A. 10, 1964), followed. Since such amounts were applied to tax rather than interest, petitioners are not entitled to an interest deduction under sec. 163(a), I.R.C. 1954. Held, further, that petitioner-husband realized…
1Opinion of the Court
John A. Amos, Petitioner v. Commissioner of Internal Revenue, Respondent; John A. Amos and Gertrude P. Amos, Petitioners v. Commissioner of Internal Revenue, Respondent
Amos v. Comm'r
Docket Nos. 4880-64, 4949-64
United States Tax Court
47 T.C. 65; 1966 U.S. Tax Ct. LEXIS 27;
October 19, 1966, Filed
Decisions will be entered under Rule 50.
Held, that amounts received by a district director, as agent for respondent, from notices of levy served on a bank and an insurance company to reach property of petitioner-husband constitute involuntary payments which the district director has a right to apply as…
2Cases cited16 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Crane v. CommissionerSupreme Court of the United States · 1947
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Norene R. O'Dell v. United States of America and Jack Ruhter, Trustee in BankruptcyCourt of Appeals for the Tenth Circuit · 1964
- Amos v. Comm'rUnited States Tax Court · 1966
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